Patna High Court
Satyam Kumar @ Satyam Kumar MandalversusThe State of Bihar
- Decided
- Disposal
- ALLOWED
- Bench
- ASHOK KUMAR PANDEY
Holding
The Court granted bail to the petitioner, directing him to furnish a bail bond of Rs.10,000 with two sureties.
Summary
The petitioner, Satyam Kumar, was arrested in connection with the death of his wife, who was allegedly killed by hanging following a dowry dispute. The prosecution alleged that the petitioner and his family hanged the deceased, while the defence argued that the death was a suicide, supported by the post‑mortem report showing asphyxia due to hanging and an independent witness statement. The petitioner, who has no prior criminal record, applied for bail under Sections 80(2) and 3(5) of the B.N.S., 2023. The State opposed bail, emphasizing the dowry demand and the short interval between marriage and death. After hearing both sides, the Court found the evidence insufficient to deny bail and ordered the petitioner to be released on a bail bond of Rs.10,000 with two sureties. The bail order was issued by Justice Ashok Kumar Pandey.
Issues considered
- Whether bail should be granted to the accused under Sections 80(2) and 3(5) of the B.N.S., 2023 in a case of alleged dowry‑related homicide.
- Whether the circumstances of the death indicate murder or suicide, and how that impacts bail considerations.
Legislation cited
- B.N.S., 2023 — s. 108, 3(5), 80(2)
Subjects
- bail
- dowry death
- murder
- suicide
- criminal procedure
- Section 80
- Section 3
- Section 108
- dowry harassment
Judgment
IN THE HIGH COURT OF JUDICATURE AT PATNA
CRIMINAL MISCELLANEOUS No.76219 of 2025
Arising Out of PS. Case No.-119 Year-2025 Thana- SIKTI District- Araria
======================================================
Satyam Kumar @ Satyam Kumar Mandal S/O Sanjay Mandal R/O Vill.- Tira
Khardah, Ward no. 4, P.S.- Sikty, Dist.- Araria.
... ... Petitioner/s
Versus
The State of Bihar
... ... Opposite Party/s
======================================================
Appearance :
For the Petitioner/s : Mr. Ramesh Kumar Singh, Advocate
For the Opposite Party/s : Mr. Akshay Lal Pandit, APP
======================================================
CORAM: HONOURABLE MR. JUSTICE ASHOK KUMAR PANDEY
ORAL ORDER
3 13-01-2026 Heard Mr. Ramesh Kumar Singh, learned counsel
for the petitioner and Mr. Akshay Lal Pandit, learned APP for
the State.
2. The petitioner has prayed for bail in connection
with Sikty P.S. Case No. 119 of 2025 registered for the offence
punishable under Sections 80(2), 3(5) of the B.N.S., 2023.
3. The case of the prosecution in short is that the
daughter of the informant was married to the petitioner on
06.02.2025. It is further alleged that she was subjected to cruelty
by the in-laws due to non-fulfillment of the dowry demand of
Rs. 5,00,000/-. The informant came to know from the villagers
that his daughter has been killed. The informant has alleged that
the petitioner, along with his family members, has hanged the
deceased.
Patna High Court CR. MISC. No.76219 of 2025(3) dt.13-01-2026
2/3
4. Learned counsel appearing on behalf of the
petitioner has submitted that petitioner is innocent and has
committed no offence. He has been falsely implicated in this
case. Learned counsel for the petitioner submits that from the
perusal of the postmortem report, it will transpire that the team
of doctors conducting the autopsy of the deceased has opined
that the cause of death is due to asphyxia as a result of hanging
and only one antemortem injury, i.e., a single blackish-brown
ligature mark over the thyroid cartilage from the left mastoid
region to the right mastoid region, approximately 1 cm wide. He
also submits that this goes to show that it is a case of hanging. It
has further been submitted that the deceased has committed
suicide, and after the investigation, the police have submitted a
chargesheet under Section 108 of the BNS. He further submits
that during the course of investigation, the independent
witnesses have stated that the deceased and the petitioner was
smoking a cigarette; thereupon, hot talk took place between
them. The deceased went in the house and hanged herself. When
the witnesses went there, they found the door was bolted from
inside and the deceased was hanging there. This statement is
there in paragraphs 64 and 66 of the case diary. He further
submits that a statement has been made in para 3 of the petition
Patna High Court CR. MISC. No.76219 of 2025(3) dt.13-01-2026
3/3
that petitioner has no criminal antecedent and he is languishing
in judicial custody since 11.08.2025.
5. The application for bail is opposed by learned APP
for the State and the learned counsel for the informant and
submits that the deceased was married on 06.02.2025 and the
death was caused within six months of the marriage. It has
further been submitted that there was demand of Rs. Five lakhs
as dowry.
6. Having heard learned counsel for the parties and
considering the facts and circumstances of the case, this Court is
inclined to enlarge the petitioner on bail. The above named
petitioner is directed to be enlarged on bail on furnishing bail
bond of Rs. 10,000/- (Rs. ten thousand only) with two sureties
of the like amount each to the satisfaction of the learned Judicial
Magistrate, 1st Class, Araria in connection with Sikty P.S. Case
No. 119 of 2025.
(Ashok Kumar Pandey, J)
Sudhanshu/-
U T
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